2454 final report.pdf - Agra CEAS Consulting

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Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) Area Benefit Beneficiaries ensuring risk-free products Ecosystems Avoid/reduce damage to ecosystems due to pesticide applications Society in general, especially people concerned with environmental issues Biodiversity Avoid/reduce destruction of biodiversity Society in general, especially people because of disruption of habitats, species concerned with environmental issues extinction Rural Avoid/reduce disruption of rural communities Rural communities communities due to loss of earnings or quitting agriculture Natural heritage Avoid/reduce disturbance of part of a nation‘s Society in general natural heritage Recreation Avoid/reduce destruction of garden plants Amateur in gardening activities Visual amenity Avoid/reduce changes in country landscape or in urban gardens/green spaces. Society in general Source: compiled by FCEC 3.11.4 Administrative and other operational costs The methodology that has been followed in the evaluation for the analysis of the administrative and other compliance costs of the CPHR was outlined in section 1.5. Before entering into the details of the results of the cost modelling, it is important to note that, according to existing literature, the CPHR is not among the most burdensome EU legislation: A German study on administrative costs 215 identifies the 100 most costly information obligations. None of the identified obligations refers to the plant health legislation; The EU project on baseline measurement and reduction of administrative costs 216 analyses the administrative costs for business associated to 7 areas of legislation 217 within the Food Safety Priority Area, among which Directive 2000/29/EC. The results of the study indicates that Directive 2000/29/EC is the second least costly legislation as regards the administrative costs for business, just after Regulation (EC) No 1830/2003 on GMO traceability. The results of the cost analysis are presented hereafter by distinguishing between the costs for the MS Competent Authorities, the Commission and the private operators. 215 Federal Government, Administrative costs: the effort to identify, measure and reduce them, The 2007 Federal Government Report on the Use of the Standard Cost Model. 216 Deloitte, Capgemini and Ramboll, EU project on baseline measurement and reduction of administrative costs, March 2009l 217 Regulation (EC) no 1/2005 on the protection of animals during transport, Regulation (EC) No 1830/2003 on GMO traceability, Directive 98/6/EC on indication of prices on products, Regulation (EC) No 1760/2000 on registration of bovine animals and beef labelling, Regulation (EC) No 21/2004 establishing an identification system for ovine and caprine animals, Directive 2000/29/EC on protective measures for plants and plant products, Directive 2000/13/EC on labelling, presentation and advertising of foodstuffs. FCEC 220
Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) 3.11.4.1 CPHR costs for the Competent Authorities Based on the data provided for the tasks considered in the cost analysis (see Table 1-4), the total costs for the 24 MS CAs 218 amount to € 59,218,314 on average per year. This total cost is a ‗net cost‘, i.e. it takes into account the revenues from the fees 219 charged to the private operators for 1) documentary, identity and plant health checks at imports; 2) inspections at the place of production; 3) registration and 4) authorization to issue plant passport. The total amount recovered through fees by the 24 MS CAs for these four tasks is estimated at 36,914,993€ 220 on average per year. Overall, the fees collected for import inspection and for inspection at the place of production respectively represent 67.3% and 56.32% of the costs incurred by the CAs for carrying out these obligations. However, important differences appear between MS, for instance, the fees collected for imports checks varies between 34% and 100% of costs incurred by the CA (based on the data available for 18 MS CAs). Table 3-27: Average annual administrative and compliance costs for CAs (EU 24) Obligations Competent Authorities Administrative Substantive Total Obligation 1: Registration EU 24 1,236,625 0 1,236,625 Obligation 2: Authorization to issue Plant Passport EU 24 101,272 0 101,272 Obligation 3: Issuance of plant passport EU 24 3,164,606 0 3,164,606 Obligation 4: Notification of interceptions in trade EU 24 217,368 0 217,368 Obligation 5: keeping of records EU 24 Obligation 6: Check the correct and uniform application of CPHR EU 24 277,774 0 277,774 Obligation 7: Submission and treatment of applications for Solidarity Funding EU 24 28,322 0 28,322 218 As outlined in section 1.5.4, of the 25 MS that responded to the specific cost survey, the analysis was only possible for 24 MS, as in the case of 1 MS the response was incomplete. 219 Pursuant to Article 13d(1) of Directive 2000/29/EC, MS shall ensure the collection of fees (Phytosanitary fee) to cover the costs occasioned by documentary checks, identity checks and plant health checks, for some of the obligations listed in the Directive. 220 The calculation of total fees for import checks is based on the assumption that all MS charge fees except IE where fees on import inspection are not yet applied (see FVO mission to Ireland DG SANCO/ 2008 7891 and 7893). Data on fees have been provided by AT, BE, CZ, DK, EE, FI, FR, HU, LV, LT, MT, NL, PL, PT, SI, SK, SE,and UK and have been estimated by FCEC for the other ones. The calculation of fees for checks at the place of production is based on the fact that 17 MS have indicated they collect fees for that purpose, of which AT, BE, DK, FI, FR, HU, LV, LT, NL, PL, PT, SI, SK, SE,and UK have provided data. Estimation has been made by FCEC for the 2 remaining ones. FCEC 221
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